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Massachusetts Wage Act Claims for Unpaid Bonuses Dismissed

March 5, 2025

A recent Massachusetts ruling regarding unpaid bonuses is extremely important for employers in light of the wave of litigation involving the Massachusetts Wage Act. In this case, Plaintiff brought claims under the Massachusetts Wage Act for unpaid bonuses under ERISA, alleging that her former employer deprived her of guaranteed bonus payments.


This case is of particular interest as it is rare for a court to consider the substantive nature of a case during the dismissal stage. However, in this case, the judge ruled on the substantive nature of the wages Plaintiff claimed, outside of the purview of a typical motion to dismiss decision. The court decided that the compensation of a bonus under ERISA is “discretionary or contingent upon the employee remaining with the company [and] is not considered a wage subject to the wage act” and dismissed the claims of unpaid wages, only allowing the retaliation claims to proceed. The judge found that bonuses did not constitute wages as they are not earned.


This decision can help to decrease employers’ concerns about wage claims, particularly those related to bonuses and deferred compensation.



If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.

Royal was Proud to Sponsor the 2025 BusinessWest Difference Makers Event!

April 10, 2025
Though the Difference Makers event has come to a close, let's continue to shine a light on the transformative power of giving back to our community! Every year, The Royal Law Firm is humbled to be a part of this incredible event that spotlights the brightest stars in our community. We can't wait to celebrate the 2026 Difference Makers and the boundless impact they'll have!

Appellate Court Affirms ADA Right to Accommodation

April 9, 2025
The United States District Court for the Northern District of New York issued an order granting summary judgment in favor of the Defendant, a school district, in a claim brought pursuant to the Americans with Disabilities Act (ADA). The Court agreed that the Plaintiff, a teacher, did not qualify for accommodation under the ADA because she could perform her job fully without the accommodation. It was agreed upon that her job functions could be performed but under “great duress and harm.” The Plaintiff appealed this decision to the United States Court of Appeals for the Second Circuit. The Court disagreed with the USDC NY decision, stating that “an employee may qualify for a reasonable accommodation even if she can perform the essential functions of her job without the accommodation.” For Employers This ruling reminds us that the crux of the ADA is if the accommodation is reasonable, aimed at mitigating disability related limitations, and does not place an undue burden on the employer, the employer is expected to fulfill that accommodation. Every request for accommodation should be looked at on a case-by-case basis. A broad metric should not be how a business decides if it should allow any requests for ADA accommodation(s). The attorneys at The Royal Law Firm are dedicated to helping employers navigate ADA accommodations and interpretations in their day-to-day practice and handbooks. If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.
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